2020 In Review, Applicable Law, Arbitration Agreement, Australia, English courts, French Law, Governing Law, Law governing the arbitration agreement, Pacific Islands, Paris Court of Appeal, Proper law of arbitration agreement, Singapore, Sweden
2020 in Review: Proper Law of Arbitration Agreement
2020 saw important case law developments concerning the proper law of arbitration agreements, where the seat of the arbitration is in a different jurisdiction from the governing law of the main contract, particularly in the UK. However, various jurisdictions have adopted different approaches to this issue. It remains to be seen which jurisdictions will follow…